Policy Statement

Help On The Way (HOTW) is committed to protecting the privacy and security of all
personal information we collect from program participants, families, service providers,
and stakeholders. We do not sell, trade, or share personal information, including phone
numbers and SMS consent, with third parties under any circumstances. This policy
ensures compliance with Campaign Registry Regulations (TCP) and other applicable
privacy laws.

Purpose

The purpose of this policy is to outline HOTW’s commitment to safeguarding personal
information. This policy explains how we collect, use, protect, and manage personal
data, including SMS communications, in line with regulatory requirements.

Scope

This policy applies to all HOTW employees, contractors, service providers, and
stakeholders involved in handling personal information, including SMS communications,
program operations, and data management systems.

Information We Collect

HOTW does NOT collect personal information through our website. We collect
information directly through communication channels with:
     •Program participants
     •Families receiving services
     •Service providers and stakeholders

Information collected includes:
     •Contact details (e.g., name, phone number, email)
     •SMS consent records
     •Communication-related data (e.g., SMS content, timestamps)

How We Use Your Information

HOTW uses personal information to:
     •Provide program-related updates and service communications
     •Coordinate with program participants, families, and stakeholders
     •Respond to inquiries and provide support
     •Comply with legal and regulatory obligations

Sharing and Disclosing Information

HOTW is dedicated to protecting your privacy.

• We will never sell, trade, or share your personal information, including
  phone numbers and SMS consent, with third parties under any
  circumstances.
• No mobile information will be shared with third parties/affiliates for
  marketing/promotional purposes. All the above categories exclude text
  messaging originator opt-in data and consent; this information will not be
  shared with any third parties.

Disclosures are limited to legal obligations or operational requirements strictly
necessary for service provision.

Security of Your Information

HOTW takes the security of personal information seriously. We use multiple protocols to
safeguard data, including:

     •Encryption for secure data transmission
     •Firewalls to prevent unauthorized access
     •Secure servers for data storage
     •Restricted access controls for sensitive information

Cookies and Tracking Technologies

Although HOTW does not collect personal data via our website, we may use cookies
and similar tracking technologies to improve website performance and user experience.
     •Cookies help optimize functionality and user navigation.
     •You may disable cookies through your browser settings; however, this may affect certain website features.

Your Rights

Individuals have the right to:
     •Opt-Out: Withdraw SMS consent anytime by replying “STOP” to any message or
emailing HOTW.
     •Access: Request details about the personal information we hold.
     •Correction: Request updates to inaccurate information.
     •Deletion: Request deletion of personal data, subject to legal requirements.

For privacy-related requests, contact: info@hotwny.org | (718) 484-7810

SMS Communication Policy

HOTW uses Dialpad for SMS communications with program participants, families, and stakeholders.
     •Opt-In Message:
      “HOTW: You opted-in to receive SMS messages. Reply STOP to opt-out. Reply
          HELP to receive help. Message and data rates may apply.”
     •You may opt-out at any time by replying “STOP” or contacting HOTW directly.

TCP Compliance (Campaign Registry Regulations)

HOTW adheres to Campaign Registry Regulations (TCP) to ensure ethical and compliant SMS communication:
     •SMS messages are only sent to individuals who have provided explicit consent.
     •Opt-in and opt-out requests are securely managed through Dialpad.
     •Consent records are maintained for compliance verification.

Failure to Comply

Non-compliance with this policy may result in disciplinary actions, including
verbal/written warnings, suspension, or termination of employment.

Monitoring and Review

This policy will be reviewed annually or as needed to ensure alignment with regulatory
requirements and best practices. Modifications require approval from HOTW’s
designated authority.

Questions and Clarifications

For questions or clarification regarding this policy, please contact:
Help On The Way, Inc. (HOTW)
1344 Southern Boulevard
Bronx, NY 10459
info@hotwny.org | (718) 484-7810